Privacy Policy

Privacy Policy

This Privacy Policy describes the policies and procedures of the websites, mobile sites, or applications on which it is posted (each a “Platform”), followed by Two Sigma Investments, LP and its affiliates ("we", "our" or "us") in the collection, storage, use, disclosure, transfer or sharing of your information on this Platform and the services, features, content or applications we offer including offline personal information (collectively with the Platform, the "Services"). We receive personal information about you from various sources, including: (i) from you directly or if you register for the Platform and the Services, through your user account for the Services (your "Account"); (ii) through your use of the Services generally; (iii) your employer (iv) from third party websites and services such as private companies within the financial services industry or trade idea networks; and (v) governmental or regulatory entities from which public records are obtained. When you use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information described in this Privacy Policy. This Privacy Policy is part of the Terms of Service.

What Does This Privacy Policy Cover?

This Privacy Policy covers the treatment of personal information, which is information relating to an identified or identifiable natural person ("Personal Information") that is gathered when you are using or accessing the Services. This Privacy Policy also covers our treatment of any Personal Information that our business partners share with us or that we share with our business partners.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications ("Third Party Services") that you elect to access through the Services or to individuals that we do not manage or employ. We take no responsibility for the content or privacy policies of any Third Party Services, and we encourage you to carefully review the privacy policies of any Third Party Services that you chose to access.

What Information Do We Collect and Why?

The collection and processing of Personal Information about you may be necessary for the performance of any contractual relationship with you, and where in our legitimate interests. For each of the categories listed below, we may use this information: (i) to contact you and respond to your requests and queries; (ii) to provide you with the Services including to enable us to conduct ancillary activities in relation to provision of Services to you, including relevant security, communications or information technology activities; (iii) for business administration, including but not limited to statistical analysis and research and analyzing performance; (iv) to personalize your visit to the Platform and assist you while you use the Platform; (v) to optimize the Platform and improve, upgrade or enhance services; (vi) for fraud prevention and detection and ensuring quality and safety of the services; (vii) to comply with applicable laws, rules and regulations including to conduct our internal audits or perform risk management, compliance monitoring or other compliance functions; (viii) for selection and on-boarding; (ix) to debug and identify and repair errors that impair existing intended functionality; (x) to market the Services and to the extent permissible under laws and regulations, market our other services or services of our affiliates; (xi) to enforce our legal rights and interests or legal rights and interest of our affiliates; and (xii) for any other purpose as described in this Privacy Policy (collectively, the “Purposes”).

For each of the categories listed below, we may share this information with various parties including Two Sigma affiliates, agents or service providers such as cloud providers, third parties you direct us to, government agencies and regulators to comply with the law and protect ourselves, business transfers, business successors, other users on the Platform if you elect to share or is made public such as postings or username, and third parties you elect to share information with through our Services.

The information we gather is used in our business and in providing the Services. In connection with certain aspects of the Services, we may request or otherwise collect and may display some of your Personal Information. We collect the following categories of Personal Information from our users.

Personal Identifiers / Account Information:

When you create an Account or we create an account on your behalf, you will provide information that could be Personal Information, such as your username, password, email address, firm, relevant financial industry identification number, occupational data, such as your background and employment information and coverage areas, and such other information is as requested on our registration page or otherwise requested through correspondences with you ("Account Information"). You acknowledge that this information may be personal to you and that, by creating an account on the Services and providing Personal Information to us, you allow us to identify you and therefore you may not remain anonymous to us. You acknowledge also that by posting information on the Platform or transmitting information to others through the Services you may be disclosing Personal Information to persons other than us. We may use your contact information to send you messages containing information about our Services. You may unsubscribe from these messages through your Account settings, and you agree that we reserve the right to contact you when we believe it is necessary, such as for account recovery purposes.

We collect this information from various sources including directly from you, your use of the Platform or Services, your employer, third-party companies within the financial services industry or trade idea networks and governmental or regulatory entities from which public records are obtained. We use and share this information as noted above in this section.

Professional and Employment Information:

We collect information related to your professional background and employment information such as your employer or firm name, relevant financial industry identification number and relevant public reports from regulatory agencies, and occupational data, such as your background and coverage areas.

We collect this information from various sources including directly from you, your use of the Platform or Services, your employer, third-party companies within the financial services industry or trade idea networks and governmental or regulatory entities from which public records are obtained. We use and share this information as noted above in this section.

Educational Information:

We collect information related to your education and credentials.

We collect this information from various sources including directly from you, your employer, third-party companies within the financial services industry or trade idea networks and governmental or regulatory entities from which public records are obtained. We use and share this information as noted above in this section.

User Content:

Some features of the Services allow you to provide content to the Services, such as written comments, trade ideas, research and other types of information regarding markets, issuers, instruments or contracts, including without limitation securities, commodities, currencies or any financial instrument or contract for exchange of value, services or risk traded on any market or otherwise, through various communications platforms including any proprietary system created by or for us. All content submitted by you to the Services may be retained by us indefinitely, even after you terminate your Account. We may continue to disclose such content to third parties as described in this Privacy Policy in a manner that does not reveal Personal Information.

We collect this information from various sources including directly from you and your use of the Platform or Services and third-party companies within the financial services industry or trade idea networks. We use and share this information as noted above in this section.

Internet or electronic network activity:

We collect this information from various sources including directly from you and your use of the Platform or Services. We use and share this information as noted above in this section.

Geolocation Information:

We collect location information such as IP address when you use our Services.

We collect this information from various sources including directly from you and your use of the Platform or Services. We use and share this information as noted above in this section.

Aggregate Information:

We collect statistical information about how users use the Services ("Aggregate Information"). Some of this information is derived from Personal Information. This statistical information is not Personal Information.

We collect this information from various sources including directly from you, your use of the Platform or Services, your employer, third-party companies within the financial services industry or trade idea networks and governmental or regulatory entities from which public records are obtained. We use and share this information as noted above in this section.

How, and With Whom, Is My Information Shared?

The Services are designed in part to help you share information with others. As a result, some of the information generated through the Services is shared with other registered users or with third parties. Such information may contain Personal Information about you. For each category of Personal Information listed above, we may share your Personal Information as follows:

Information Shared with Our Affiliates:

We may share your Personal Information within the Two Sigma family of companies.

Information Shared with Our Agents or Service Providers:

We employ and contract with individuals and entities that perform certain tasks on our behalf and who are under our control (our "Agents" or “Service Providers”). We may need to share Personal Information with our Agents or Service Providers in order to provide products or services to you (e.g., cloud providers, workplace solution providers, etc.) or to manage our processes.

Information Disclosed Pursuant to Business Transfers:

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this Privacy Policy.

Information We Share With Your Consent:

We will also share your Personal Information in the manner that you authorize us to.

Information We Share to Comply with the Law or Protect Ourselves

We will share personal information if we think we have to in order to comply with the law or to protect ourselves such as responding to court orders or subpoenas. We may also share your personal information if a government agency or investigatory body requests. We may also use your personal information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.

Information shared with Successor to all or part of our Business

We may share your Personal Information for example in the event of a merger, acquisition, divestiture, change of control, or liquidation of Two Sigma or part of its business (or in anticipation of such event).

Public Information about Your Activity on the Services:

Some of your activity on and through the Services is made available to other registered users by default. This may include, but is not limited to, content you have posted on the Platform or otherwise through the Services. Registered users may have some of this information associated with their Accounts.

Please also remember that Personal Information that you may choose to provide using certain features of the Services may be available to other registered users. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge. We therefore urge you to think carefully about including any specific information you may deem private in Content that you create for or submit through the Services.

IP Address Information:

We collect and store IP address information, and at times, we share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.

Information You Elect to Share:

You may access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within the Platform. We are not responsible for the privacy policies or practices of these Third Party Services. This Privacy Policy only governs information collected on the Services.

Aggregate Information:

We may share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We may elect to share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites. In addition, these third parties may share with us non-private, aggregated or otherwise non-Personal Information about you that they have independently developed or acquired.

Communications with Us:

As part of the Services, you may occasionally receive email and other communications from us, such as communications relating to your Account and our services. Communications relating to your Account will only be sent for purposes important to the Services, such as password recovery. If you use our mobile app, we may also use push notifications on our mobile apps. We may also send emails containing surveys regarding various topics. The results of these surveys may be shared with other users.

User Profile Information:

User profile information including your username and other information you enter may be displayed to other users. We will not directly reveal user email addresses to other users.

Is Information About Me Secure?

Your profile and registration information relating to your Account Information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer, browser and/or mobile device by signing off after you have finished accessing your Account.

We take reasonable steps consistent with industry standards, including technical, administrative and physical safeguards to protect the Personal Information submitted to us from loss, misuse and unauthorized access, disclosure, alteration or destruction. However, no method of security over the Internet is entirely secure.

We do not guarantee the security of any Account Information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

We keep your Personal Information for as long as it is necessary or relevant for the practices described in this Privacy Policy. We will also keep your Personal Information as otherwise required by law or for internal compliance and record-keeping purposes.

What Information of Mine Can I Access?

If you are a registered user, you can access certain information associated with your Account by logging into the Services. Registered and unregistered users can access and delete cookies through their web browser settings.

You may ask us for a notice identifying the categories of personal information which we share with our affiliates and third parties for marketing purposes, and to provide contact information for such affiliates and third parties. If you would like a copy of this notice, please submit a written request to the following address: 100 Avenue of Americas, 16th floor, New York, NY 10013.

Storage of Information

Information we maintain may be stored both within and outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your information to the United States. This Platform is subject to U.S. laws, which may not afford the same level of protection as those in your country.

How Can I Terminate My Account?

Should you ever decide to terminate your Account, you may do so by emailing pics.support@twosigma.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, in accordance with our Terms of Service, we may continue to store and use information that you disclosed prior to termination. Please note that we will need to verify that you have the authority to terminate the Account.

What Choices Do I Have Regarding My Information?

I am located in the European Economic Area and United Kingdom:

Individuals who are located in or residents of countries in the European Economic Area (“EEA”) and the United Kingdom (“UK”) have certain data subject rights which may be subject to limitations and/or restrictions.

You may have a right to access, rectify and, subject to our other legal obligations and business considerations, erase your Personal Information. You also have a right to restrict or to object to the processing of your Personal Information as well as a right to data portability. You may also have the right to lodge a complaint about the processing of your Personal Information with your local data protection authority.

Please note that you have a right to object to processing of your personal data where that processing is carried out for our legitimate interest or for direct marketing.

If you wish to exercise any of your rights under this Privacy Policy, please send us a request via email to GDPR@twosigma.com.

For the purposes of EEA and UK data protection laws, we are the data controller or your Personal Information collected when you are using or access the Platform. This means that we are responsible for, and control the processing of, your personal information.

UK inquiries: Our data protection representative in the UK is Two Sigma International Limited, and can be reached at GDPR@twosigma.com.

EEA inquiries: Leo RegTech Limited, incorporated and registered in England and Wales with company number 04829021, acting through its French branch located at 128 rue de la Boétie 75008, Paris, France, is a designated representative of Two Sigma Investments, LP (the “Company”) in the European Union, in accordance with article 27 of the EU General Data Protection Regulation (2016/679/EU) (the “GDPR”). The Company has mandated Leo and its branch to be the EU Representative of the Company with regards to any communications or enquiry from the Supervisory Authority and/or data subjects on all issues related to the processing of personal data. If you are in the EU, please contact Leo at the following details: Email: eurorep@leo.tech; Address: FAO EuroRep, c/o Leo, 128 rue de la Boétie 75008, Paris, France. When contacting Leo regarding the Company, please quote the name of the Company and the Ref: 0085.

For the purposes of EEA and UK data protection laws, the legal basis for the processing of your Personal Information are when it is necessary for the performance of any contractual relationship with you, and where in our legitimate interests for the purposes described in this Privacy Policy.

The Platform is controlled and operated by us from the U.S. and we use third parties providers to support the Platform and perform the Services. As a result, Personal Information that we collect about you or that you provide to us while using the Platform will be transferred and hosted in the U.S. or other countries which does not provide a similar level of protection to that provided by the countries in the EEA. By using the Platform, you consent to the transfer of your Personal Information outside of the EEA. You acknowledge that if you do not consent or withdraw your consent by sending an email to GDPR@twosigma.com to such transfer it may impact your ability to use the Services.

We generally retain personal data for so long as it may be relevant to the purposes set forth in the relevant privacy policy. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information. For example, we retain a record of your inquiries to us for as long as it takes to fulfill the inquiry. If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. To dispose of your information, we may de-identify it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

I am located in California:

If you are a California resident, California law requires us to provide you with certain information about how we collect, use, and disclose your “personal information” as defined in the California Consumer Privacy Act (“CCPA”). Please note that this California Privacy Notice (“Notice”) applies only to information we collect from California consumers, and does not apply to any individual in their capacity as a) a Two Sigma investor or b) a Two Sigma employee. For more information about the privacy practices of our individual businesses, please see each business’s main Privacy Policy.

We collect the following categories of personal information defined under the CCPA from California consumers and that we may, as discussed throughout this Policy, use and disclose for our business purposes:

Identifiers (such as name, address, email address); device identifiers (such as IP address and unique device identifiers); internet or other network or device activity (such as browsing history); general geolocation data derived from IP addresses; any user-generated content or feedback that you provide (including in connection with participation in our programs); professional, educational or employment related data; and username and password.

If you perform services for Two Sigma as an independent contractor, we may also collect additional information from you, such as additional identifiers (like social security number, drivers’ license number, or other government identifiers), citizenship or immigration documentation, and financial information to facilitate payments to you.

We collect such information: directly from you (such as when you contribute to or participate in one of our programs, apply for a job with Two Sigma, submit your business contact information, or send us questions or otherwise communicate with us); through automated technology (such as cookies on our websites) or online platforms; from third parties such as recruiting platforms and events, referrals, financial institutions, or your employer; and from other sources (such as publicly available information).

We and our service providers may use the categories of personal information we collect from and about you for the following business and commercial purposes (as those terms are defined in applicable law):

We may also use and disclose personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any user or device, and use such aggregate and de-identified information for any purpose.

We may also disclose this information to third parties for legal, compliance or security purposes or based on your elections, in connection with a business transfer or successor to all or part of the business, or our affiliates.

The CCPA sets forth certain obligations for businesses that “sell” personal information or “share” personal information for cross-context behavioral advertising purposes with third parties who do not act as service providers to that business. Two Sigma makes personal information available to non-service provider third parties only when individuals have affirmatively agreed to such disclosure (for example, where a site visitor has opted in to our use of advertising cookies) or where the disclosure of personal information is otherwise exempt from the CCPA (such as disclosing information to secure the Services). As such, Two Sigma does not “sell” or “share” personal information within the meaning of the CCPA.

Please note, in the limited circumstances that we process sensitive personal information as defined in the CCPA, we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA.

California residents may make certain requests about their personal information under the CCPA, subject to certain limitations and/or restrictions. Specifically, under California law you have the right to:

A consumer may use an authorized agent to submit a request on their behalf. When using an authorized agent, we require that you provide the authorized agent written permission to do so and verify their own identity and agent status with us. If you would like to designate an authorized agent to make a request on your behalf, please email us at CCPA@twosigma.com.

If you require this notice in an alternative accessible format, please email us at CCPA@twosigma.com.

We have instituted a process for verifying that the person making an access, correction or deletion request is the consumer about whom we have collected information. Whenever feasible, we will match at least two data points in the identifying information provided by the consumer to the personal information already maintained by us, but it may require more data points depending on the information requested. We will avoid collecting highly sensitive pieces of personal information, unless necessary. For online requests to delete, we will use a two-step process where the consumer must first submit the deletion request and then separately confirm that they want their personal information deleted. If we cannot verify your identity in accordance with California law, we may deny your request in whole or in part.

For requests to know and requests to delete, we will confirm receipt of the request within ten (10) days and provide information about how the business will process the request, and we will respond within 45 days with an option to extend an additional 45 days provided we give you notice.

If you wish to exercise any of your rights under this section, you may submit your request through any of these methods: (i) email us at CCPA@twosigma.com; (ii) contact us at the toll-free telephone number 1-844-820-6577; or (iii) submit a webform request here.

California Law permits customers who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

We generally retain personal data for so long as it may be relevant to the purposes set forth in the relevant privacy policy. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information. For example, we retain a record of your inquiries to us for as long as it takes to fulfill the inquiry. If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. To dispose of your information, we may de-identify it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

I am located in China:

You hereby consent that we can collect, store, use and process relevant information (including your Personal Information) provided by you or accessible by us pursuant to the terms of this Privacy Policy as necessary or appropriate for the Purposes. You further consent that we may transfer and disclose such information (including your Personal Information) to the following recipient(s) globally, to the extent that such transfer or disclosure is necessary or appropriate for the Purposes: (i) any member of our affiliates (including our head office, parent company, affiliates, branches and subsidiaries located in or outside China); (ii) our and our affiliates’ respective professional advisers, independent contractors or Agents (located in or outside China); (iv) our business partners (located in or outside China); (v) regulators and law enforcement agencies of any jurisdiction where we and our affiliates conduct businesses and are required to use or disclose such information to meet our respective compliance obligations under applicable laws and regulations; and (iv) other recipients as set out in this Privacy Policy to the extent not expressly prohibited by the PRC law.

You agree that the information provided by you will not involve (i) any State secrets or sensitive information which may potentially constitute State secrets as defined under the PRC State Secrets Law, (ii) confidential information and important data of operators of critical information infrastructure (“CII”) as defined under the PRC Cybersecurity Law and relevant regulations unless necessary consents and/or approvals for disclosure have been received pursuant to applicable law; (iii) Personal Information or Personal Financial Information of others unless consents from relevant information owners have been received and you have the authority to pass these information to us; (iv) other sensitive information the collection, use, process, disclosure or transfer (including cross-border transfer) of which is subject to restrictions under PRC law unless necessary consents and/or approvals have been received and relevant compliance requirements are met.

You may have a right to access, rectify and modify the information that you provide to us, or cease to consent to our continued collection, use or processing of your Personal Information or request to erase your Personal Information pursuant to the terms of this Privacy Policy. You also have a right to restrict or to object to the processing, sharing or disclosing of your Personal Information to the extent permissible under PRC law.

What Happens When There Are Changes to this Privacy Policy?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make material changes in the way we collect or use information, we will notify you as required by law, which may include by posting an announcement on the Services or sending you an email. A user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.

What If I Have Questions or Concerns?

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to pics.support@twosigma.com. We will make every effort to resolve your concerns.

Effective Date: June 28, 2023